OSHA Inspection: MONFORT INC., PORK DIVISION

Issued

Dec 16, 1993

Abate by

Dec 19, 1994

Penalty

Initial $70,000 · Current $35,000 Reduced

General-duty citation text

not limited to, the following:
i) Provide larger conveyor work area.
ii)Provide adjustable height work platform.
(ah)Remove Body Bones:  Evaluation of this task indicates that
employees are exposed to
the ergonomic stressors of shoulder abduction, wrist flexion and
extension, wrist pronation
and supination, ulnar deviation, high grip forces, and frequency of
repetition which are
Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
causing or are likely to cause cumulative trauma disorders.  (Note
bone shanks and
remove body bones were one task).
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide larger conveyor work area.
ii)Provide adjustable height work platform.
(ai)Trim Finger:  Evaluation of this task indicates that employees are
exposed to the
employer did not
ergonomic stressors of shoulder abduction, wrist flexion, and
frequency of repetition which
are causing or are likely to cause cumulative trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide larger conveyor work area.
ii)Provide adjustable height work platform.
(aj)Remove Inner Shank/Outer Shank:  Evaluation of this task indicates
that employees
furnish employment and a place of employment which was free from
are exposed to the ergonomic stressors of shoulder extension, torso
twisting, and frequency
of repetition which are causing or are likely to cause cumulative
trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide larger conveyor work area.
ii)Provide adjustable height work platform.
ABATEMENT METHODS:
recognized hazards that
Feasible means to correct these hazards include the implementation of a
comprehensive written
ergonomics management program, developed by a qualified ergonomist, which
includes, but is
not limited to, the following elements:
I.  WORKSITE ANALYSIS to recognize and identify existing ergonomic risk
factors in the
workplace.  This analysis shall include development and use of an
ergonomic illness checklist
and employee questionnaire.  Frequent surveys of the workplace shall be
were causing or likely to cause serious physical harm to employees in
conducted by a
that employees were
required to perform tasks involving identified ergonomic risk factors
including, but not limited
to, repetitive motions, high force and/or awkward postures, resulting in
stressors that had
qualified ergonomist to identify and evaluate ergonomic stressors and the
work practices and
engineering controls needed for their abatement.  The survey shall
include a job analysis of all
high risk, restricted duty, and other jobs used within an administrative
control schema.  The
job analysis shall specifically identify all ergonomic stressors and the
body
part affected.
caused, were causing, or were likely to cause cumulative trauma
Employee participation in the program shall be encouraged through a
mechanism such as a
safety committee.
II.  HAZARD PREVENTION AND CONTROL which includes the development and use
of
engineering, work practice and administrative control measures and
personal protective
equipment, where deemed relevant.
(a)Engineering controls shall be designed by a qualified ergonomist
and may include
disorder(s):
workstation redesign, tool redesign, and changes in work methods.  The
goal of this
program shall be to make the job fit the person.  See the examples of
engineering controls
applicable to the cited workstations listed above.
(b)Administrative controls shall be implemented which reduce the
duration, frequency,
and severity of employee exposure to ergonomic stressors.  These
controls may include,
but are not limited to, job rotation and reduction of repetition rate
(a)Shackle Hogs:  Evaluation of this task indicates that employees are
through additional
staffing or the reduction of line speeds.  For any administrative
control schema, a detailed
job analysis must be performed on each job within the schema to assure
that parallel
stressors, body part movements or musculo-skeletal system usage are
not present.  A
preventive maintenance program for engineering controls shall be
developed and
implemented.
exposed to the
The affect of the utilization of various types of personal
protective equipment shall
be evaluated to assure that currently used equipment is not
exacerbating or causing
ergonomic stressors.
(c)Work practice controls shall be implemented which may include, but
are not limited
to, proper work techniques, new employee conditioning and ramp-in of
injured employees
or of employees returning from leave or other absences.
ergonomic stressors of shoulder abduction and flexion, wrist flexion
III.  TRAINING AND EDUCATION of employees.  Training shall address the
and extension, ulnar
deviation, high force, and frequency of repetition which are causing
or are likely to cause
cumulative trauma disorders.
Examples of engineering controls applicable to this workplace may
hazards
associated with the job, the risk factors which cause cumulative trauma
disorders (CTDs),
symptoms of exposure including signs and symptoms of CTDs, and how to
prevent the
occurrence
of CTDs including the use of engineering and administrative
controls and their
maintenance.
include,
Retraining shall be performed at least annually and as operations
change.  Supervisors
shall receive additional training sufficient to assure competency in the
oversight of the program
and control measures within their areas of responsibility.  Plant
engineers and maintenance
personnel shall be trained in the prevention and correction of ergonomic
hazards through job
and work station design and proper maintenance, both in general and as
applied to the specific
but are
conditions of the facility.  Methods to evaluate the effectiveness of the
training shall be
developed and implemented.
not limited to, the following:
i) Provide additional in process storage space on conveyor or work
area.
ii)Provide additional crewing.
iii)Rearrange work position to reduce reaching for shackle.
iv)Provide adjustable height work stand.
(b)Position Hogs:  Evaluation of this task indicates that employees
are exposed to the
ergonomic stressors of back flexion, shoulder flexion and abduction,
pushing and pulling
forces, high grip forces, and frequency of repetition which are
causing or are likely to
cause cumulative trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide conveyor/chute that aligns hogs.
ii)Provide a dehair process that ejects with proper alignment.
(c)Drop Heads:  Evaluation of this task indicates that employees are
exposed to the
ergonomic stressors of shoulder abduction, shoulder flexion, back
flexion, wrist pronation
and supination, high finger pinch and hand grip forces, and frequency
of repetition which
are causing or are likely to cause cumulative trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide adjustable height work stands.
ii)Adjust work area to allow worker to be closer (4-6 inches) to
animals.
(d)Trim Heads USDA:  Evaluation of this task indicates that employees
are exposed to
the ergonomic stressors of shoulder abduction and flexion, wrist
extension
and flexion,
ulnar deviation, high grip forces, and frequency of repetition which
are causing or are
likely to cause cumulative trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Suspend powered trimmers.
ii)Provide additional crewing.
iii)Provide adjustable height work platform.
(e)Place Spreader Hooks:  Evaluation of this task indicates that
employees are exposed
to the ergonomic stressors of shoulder abduction and flexion, pulling
forces, torso twisting,
high finger forces, and frequency of repetition which are causing or
are likely to cause
cumulative trauma disorders.
Examples of engineering controls applicable to this workplace may
include,
but are
not limited to, the following:
i) Provide adjustable height work platforms.
ii)Provide work area closer (4-6 inches) to animals.
(f)Gut Hogs:  Evaluation of this task indicates that employees are
exposed to the
ergonomic stressors of shoulder abduction, wrist supination and
pronation, wrist flexion,
torso twisting, lifting, high grip forces, and frequency of repetition
which are causing or
are likely to cause cumulative trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide a conveyor system that provides gut pans under carcasses.
(g)Pull Lard:  Evaluation of this task indicates that employees are
exposed
to the
ergonomic stressors of shoulder abduction and flexion, wrist flexion,
high grip forces, and
frequency of repetition which are causing or are likely to cause
cumulative trauma
disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide usable powered lard puller.
(h)Chisel Cheeks:  Evaluation of this task indicates that employees
are exposed to the
ergonomic stressors of wrist flexion, high grip forces, and frequency
of repetition which
are causing or are likely to cause cumulative trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide clamp to hold head on rod.
(i)Remove Cheeks:  Evaluation of this task indicates that employees
are exposed to the
ergonomic stressors of wrist flexion and extension, ulnar deviation,
wrist pronation and
supination, and frequency of repetition which are causing or are
likely to cause cumulative
trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Eliminate throwing of meat, rearrange layout.
ii)Provide divergent conveyor to eliminate reaching.
iii)Provide flat surface for in process storage.
iv)Provide adjustable height holding rod.
(j)Back of Heads:  Evaluation of this task indicates that employees
are
exposed to the
ergonomic stressors of wrist flexion, shoulder abduction, ulnar
deviation, vibration, high
grip forces, and frequency of repetition which are causing or are
likely to cause cumulative
trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide a holding fixture for head.
ii)Eliminate throwing of head, provide chutes.
iii)Eliminate reach to conveyor, provide inlet work areas.
(k)Pipe Guts:  Evaluation of this task indicates that employees are
exposed to the
ergonomic stressors of wrist flexion and extension, high finger and
grip force, and
frequency of repetition which are causing or are likely to cause
cumulative trauma
disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide pipes with insertion end of pipe 3-4 inches higher than
descending curve.
ii)Provide vacuum system to pull gut.
iii)Deliver gut to task through a raised trough such that worker
guides guts rather
than pickup and push guts.
(l)Pull Pancreas:  Evaluation of this task indicates that employees
are exposed to the
ergonomic stressors of high finger pinch forces, high grip forces, and
frequency of
repetition which are causing or are likely to cause cumulative trauma
disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide a stationary fixture to cut tissue or to pull tissue
through.
ii)Provide a mechanically assisted opening/spreading device.
(m)Pull Ribs:  Evaluation of this task indicates that employees are
exposed to the
ergonomic stressors of shoulder flexion and abduction, back flexion,
radial and ulnar
deviation, torso twisting, high grip forces, and frequency of
repetition which are causing
or are likely to cause cumulative trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide a draw knife with improved quality blade.
ii)Eliminate throwing product behind worker, provide slide chute.
iii)Provide additional crewing.
(n)Fat Back Cut-off:  Evaluation of this task indicates that employees
are exposed to the
ergonomic stressors of shoulder flexion, high pinch grip forces, and
frequency of repetition
which are causing or are likely to cause cumulative trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide a divergent ramp on the conveyor that aligns belly for
cutoff.
ii)Combine task with trim fat back and use automated cutoff.
(o)Face Bellies (1400 Whiz):  Evaluation of this task indicates that
employees are
exposed to the ergonomic stressors of high grip forces, shoulder
abduction and flexion,
vibration, and frequency of repetition which are causing or are likely
to cause cumulative
trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Eliminate raised and overhead conveyors for removed product.
(p)Grade and Reduce Bellies:  Evaluation of this task indicates that
employees are
exposed to the ergonomic stressors of ulnar deviation; high
acceleration and deceleration
of arm, hand and wrist; shoulder abduction, torso twisting, wrist
flexion, high grip forces,
and frequency of repetition which are causing or are likely to cause
cumulative trauma
disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide automated grading system.
ii)Provide divergent conveyors rather than throwing product.
iii)Eliminate overhead conveyor.
(q)Skin and Hang Hams:  Evaluation of this task indicates that
employees are exposed
to the ergonomic stressors of wrist flexion, torso twisting, lifting,
high grip and finger
forces, and frequency of repetition which are causing or are likely to
cause cumulative
trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide a slide from conveyor to skinner.
ii)Reduce height of hook for hanging ham.
iii)Provide adjustable height work platform.
(r)Remove Neckbones:  Evaluation of this task indicates that employees
are exposed to
the ergonomic stressors of wrist flexion and extension, wrist
pronation
and supination,
shoulder abduction and flexion, high grip forces and finger forces,
and frequency of
repetition which are causing or are likely to cause cumulative trauma
disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Eliminate overhead conveyor.
ii)Provide additional work table space for temporary storage and a
fixed surface for
cutting.
iii)Create a holding fixture that holds and aligns meat for
improved slicing postures.
(s)Picnic skinner:  Evaluation of this task indicates that employees
are exposed to the
ergonomic stressors of wrist flexion and extension, high grip and
finger forces, and
frequency of repetition which are causing or are likely to cause
cumulative
trauma
disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide skinner that does not require continual hand support for
picnic ham to
stay on skinner.
ii)Provide slide for the product to reduce lifting and throwing.
iii)Adjust conveyor and skinner head heights to be the same.
(t)Picnic Boners:  Evaluation of this task indicates that employees
are exposed to the
ergonomic stressors of ulnar deviation, shoulder abduction and
flexion, high grip and finger
forces, and frequency of repetition which are causing or are likely to
cause cumulative
trauma disorders.
Examples of engineering controls applicable to this workplace may
include,
but are
not limited to, the following:
i) Eliminate overhead conveyor.
ii)Provide fixed work area for cutting.
iii)Provide adjustable height work platform.
(u)Inspect Boneless Picnic (Whiz):  Evaluation of this task indicates
that employees are
exposed to the ergonomic stressors of shoulder abduction, wrist
flexion, ulnar deviation,
wrist supination and pronation, high grip and finger forces, and
frequency of repetition
which are causing or are likely to cause cumulative trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide fixed work area for trimming.
ii)Eliminate overhead conveyor.
iii)Provide adjustable height work platform.
(v)Pack Butts:  Evaluation of this task indicates that employees are
exposed to the
ergonomic stressors of high finger pinch and grip forces, back
flexion, lifting, shoulder
abduction and flexion, torso twisting, palmar compression, pushing and
pulling forces, and
frequency of repetition which are causing or are likely to cause
cumulative trauma
disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Automate packaging.
ii)Provide divergent conveyors for different products.
iii)Provide adjustable work area/conveyor heights.
iv)Provide adjustable height pallet system.
v) Eliminate carrying full cases.
(w)Trim Feet:  Evaluation of this task indicates that employees are
exposed to the
ergonomic stressors of wrist flexion, radial and ulnar deviation, high
grip forces, and
frequency of repetition which are causing or are likely to cause
cumulative trauma
disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Automate.
ii)Provide mechanical assist to make both cuts simultaneously.
iii)Perform task while animal is on overhead conveyor to eliminate
holding of
workpiece.
(x)Shank Picnic:  Evaluation of this task indicates that employees are
exposed to the
ergonomic stressors of shoulder abduction, wrist flexion, ulnar
deviation, high grip and
finger forces, wrist pronation and supination, and frequency of
repetition which are causing
or are likely to cause cumulative trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Eliminate overhead conveyor.
ii)Provide fixed work area for cutting.
iii)Provide adjustable height work platform.
(y)Remove Backribs:  Evaluation of this task indicates that employees
are exposed to the
ergonomic stressors of wrist flexion, shoulder abduction, high grip
and pinch forces, and
frequency of repetition which are causing or are likely to cause
cumulative trauma
disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Eliminate throwing product behind worker, provide slide chute.
ii)Provide adjustable height work platform.
(z)Strip Tenders:  Evaluation of this task indicates that employees
are exposed to the
ergonomic stressors of high finger pinch and hand grip forces, back
flexion, shoulder
flexion, and frequency of repetition which are causing or are likely
to cause cumulative
trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide work table that is adjustable in height.
ii)Eliminate reaching over dividers to retrieve product.
iii)Provide a small post like device to assist in the initial
separation of two
components.
(aa)Ham Skinner:  Evaluation of this task indicates that employees are
exposed to the
ergonomic stressors of wrist flexion and extension, radial deviation,
lifting, high hand grip
forces, and frequency of repetition which are causing or are likely to
cause cumulative
trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide slide and work area to eliminate lifting of hams from
bins.
ii)Provide slide conveyor.
iii)Provide adjustable height work platform.
(ab)First Straight Knife:  Evaluation of this task indicates that
employees are exposed to
the ergonomic stressors of shoulder abduction, wrist flexion, high
pinch
and grip forces,
and frequency of repetition which are causing or are likely to cause
cumulative trauma
disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Eliminate throwing of trimmed material to rear of worker.
ii)Provide adjustable height work platform.
(ac)Second Straight Knife:  Evaluation of this task indicates that
employees are exposed
to the ergonomic stressors of shoulder abduction, ulnar deviation,
wrist flexion, and
frequency of repetition which are causing or are likely to cause
cumulative trauma
disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Eliminate throwing of trimmed material to rear of worker.
ii)Provide adjustable height work platform.
(ad)Defat Hams (Whiz 1400):  Evaluation of this task indicates that
employees are exposed
to the ergonomic stressors of wrist extension, high grip and finger
forces, vibration, and
frequency of repetition which are causing or are likely to cause
cumulative trauma
disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide wider conveyor work area.
ii)Provide adjustable height work platform.
(ae)Remove Aitch Bone:  Evaluation of this task indicates that
employees
are exposed to
the ergonomic stressors of shoulder abduction and adduction, wrist
flexion, wrist pronation
and supination, and frequency of repetition which are causing or are
likely to cause
cumulative trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide larger conveyor work area.
ii)Provide adjustable height work platform.
(af)Pull Faces:  Evaluation of this task indicates that employees are
exposed to the
ergonomic stressors of shoulder abduction, wrist flexion, and
frequency of repetition which
are causing or are likely to cause cumulative trauma disorders.
Examples of engineering controls applicable to this workplace may
include, but are
not limited to, the following:
i) Provide larger conveyor work area.
ii)Provide adjustable height work platform.
(ag)Bone Shanks:  Evaluation of this task indicates that employees are
exposed to the
ergonomic stressors of shoulder abduction, wrist flexion and
extension, ulnar deviation,
high grip forces, wrist pronation and supination, and frequency of
repetition which are
causing or are likely to cause cumulative trauma disorders.  (Note
bone shanks and
remove body bones were one task).
Examples of engineering controls applicable to this workplace may
include, but are

Issued

Dec 16, 1993

Abate by

Dec 19, 1994

Penalty

Initial $70,000 · Current $35,000 Reduced

General-duty citation text

appointments.
ABATEMENT OF THE CITATION SHALL BE ACCOMPLISHED IN ACCORDANCE
WITH THE FOLLOWING SCHEDULE:
STEP 1   Development of an effective ergonomics management program which
contains the
elements detailed in Abatement Methods Sections I, II, and III
for Citation 1, Item 1.
STEP 2   Submit to the Area Director a written plan of abatement which
identifies and details
Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
a schedule for the implementation of the administrative, work
practice,
and
engineering
controls as detailed in Citation 1, Item 1.
All proposed control measures shall be approved for each
particular use by an
ergonomist who is qualified in the evaluation of workplace
conditions which cause
ergonomic stressors.  One-hundred twenty (120) day progress
employer did not
reports are required
during the abatement period.
The abatement date for this step is 04/16/94
STEP 3   Implementation of administrative, work practice, and engineering
controls shall be
completed.
The abatement date for this step is 12/16/94
STEP 4   Development of an effective medical management program which
contains the
elements
furnish employment and a place of employment which was free from
detailed in Abatement Method Sections I, II, III, and IV
for Citation 1, Item
2.
STEP 5   Submit to the Area Director a written plan of abatement which
identifies and details
a schedule for the implementation of an effective medical
management program which
addresses the specific deficiencies listed in instances a - d of
Citation 1, Item 2.
The medical management program shall be developed and approved
recognized hazards that
by a medical
provider who is qualified in the recognition, evaluation and
treatment of ergonomic
related injuries and illnesses, such as CTDs.  Ninety (90) day
progress reports are
required during the abatement period.
The abatement date for this step is 03/16/94
STEP 6   Implementation of an effective medical management program which
addresses the
specific deficiencies listed in instances a - d of Citation 1,
were causing or likely to cause serious physical harm to employees in
Item 2 shall be completed.
that employees who
sustained cumulative trauma disorder(s) (CTDs) were exposed to increased
risk of aggravation
to existing injuries and illnesses and developing further injuries and
illnesses due to the fact that
The abatement date for this step is 12/16/94
the employer's written medical management program, which includes the
restricted duty policy,
was not fully implemented since the in house medical and/or management
staff failed to honor
permanent and temporary restricted duty orders, failed to follow the CTD
algorithm, and/or
failed to ensure that employees were not returned to the same or
substantially similar job which
originally caused or contributed to severe CTD signs/ symptoms and may
have resulted in
surgery:
(a)  Employee(s) experienced continued CTD signs and symptoms,
exacerbation of their
initial CTD signs and symptoms, and/or development of new CTD signs
and symptoms
due to inappropriate intervention by the in-house medical staff in
that physician's orders
of a medical disqualification and a permanent restriction were
altered and/or modified;
and due to inappropriate assignment of job tasks by management which
directly violated
the physician's orders of permanent job changes since employees were
placed in the very
job which had been prohibited.
(b)  Employee(s) experienced continued CTD signs and symptoms,
exacerbation of their
initial CTD signs and symptoms, and/or development of new CTD signs
and symptoms,
in which some cases led to surgical intervention, due to
inappropriate
assignment of job
tasks by management which directly violated temporary restrictions
ordered by the treating
physicians or in-house medical staff; and in some instances, due to
the inappropriate
intervention by the in-house medical staff in that these temporary
restrictions prescribed by
the physicians were modified and/or changed.
(c)  Employee(s) experienced continued CTD signs and symptoms,
exacerbation of their
initial CTD signs and symptoms, and/or development of new CTD signs
and symptoms,
in which some cases led to surgical intervention, due to the lack of
implementation of the
employer's written medical protocol (including the CTD algorithm)
since:
(1) Medical screening assessments by the in-house medical staff
were not adequately
performed and documented upon the presentation of CTD signs and
symptoms by
employees;
(2) Physician referrals and the assignment of restricted duty
orders by the in-house
medical staff were not prompt and timely after the presentation
of CTD signs and
symptoms by employees; and/or
(3) Reevaluation of the employee's CTD symptom status by the
in-house medical staff
was not performed at the required intervals during conservative
treatment.
(d)  Employee(s) experienced continued CTD signs and symptoms,
exacerbation of their
initial CTD signs and symptoms, and/or development of new CTD signs
and symptoms,
in which some cases led to surgical intervention, due to the return
of employees by the
inhouse
medical and management staff to inappropriate regular duty
tasks following a CTD
surgery or development of severe CTD signs and symptoms in that
employees resumed the
same or substantially similar job with the same or similar job
stressors
which caused or
contributed to the original CTD illness.
ABATEMENT METHODS:
Feasible means to correct these hazards include the implementation of a
comprehensive written
ergonomics management program, developed by a qualified ergonomist, and a
comprehensive
written medical management program developed by a qualified health care
provider, which
includes, but is not limited to, the following elements:
I.  WORKSITE ANALYSIS to recognize and identify existing ergonomic risk
factors in the
workplace.  This analysis shall include development and use of an
ergonomic illness checklist
and employee questionnaire.  Frequent surveys of the workplace shall be
conducted by a
qualified ergonomist to identify and evaluate ergonomic stressors and the
work practices and
engineering controls needed for their abatement.  The survey shall
include a job analysis of all
high risk, restricted duty, and other jobs used within an administrative
control schema.  The
job analysis shall specifically identify all ergonomic stressors and the
body part affected.
Employee participation in the program shall be encouraged through a
mechanism such as a
safety committee.
II.  HAZARD PREVENTION AND CONTROL which includes the development and use
of
engineering, work practice and administrative control measures and
personal protective
equipment,
where deemed relevant.
(a)      Engineering controls are to be designed by a qualified
ergonomist and may include
workstation redesign, tool redesign, and changes in work methods.
The goal of this
program shall be to make the job fit the person.
(b)      Administrative controls shall be implemented which reduce
the duration,
frequency, and severity of employee exposure to ergonomic stressors.
These controls may
include, but are not limited to, job rotation and reduction of
repetition rate through
additional staffing or the reduction of line speeds.  For any
administrative control schema,
a detailed job analysis must be performed on each job within the
schema to assure that
parallel stressors, body part movements or musculoskeletal system
usage are not present.
A preventive maintenance program for engineering controls shall be
developed and
implemented.
The affect of the utilization of various types of personal
protective equipment shall
be evaluated to assure that currently used equipment is not
exacerbating or causing
ergonomic stressors.
(c)      Work practice controls shall be implemented which may
include but are not
limited to proper work techniques, new employee conditioning and
ramp-in
of injured
employees or of employees returning from leave or other absences.
III.  MEDICAL MANAGEMENT to eliminate or reduce the risk of development
of CTD signs
and symptoms through early identification and treatment.  The program
shall address early
recognition, evaluation and referral of cumulative trauma disorder (CTD)
illness cases, and
shall include conservative treatment and conservative return to work,
including work hardening
prior to return to full duty.  The medical management program is to be
established under the
supervision of a physician or occupational health nurse (OHN) who has
been fully trained in
the prevention and treatment of CTDs.  Systematic worksite review by the
medical practitioners
shall also be included in the program.  The program shall include, but is
not limited to, the
following elements:
(a)  Health care providers shall be knowledgeable in the prevention,
early recognition,
evaluation, treatment and rehabilitation of CTDs, and in the
principles of ergonomics,
physical assessment of employees, and OSHA recordkeeping
requirements.  Appropriately
trained health care providers shall   be available at all times on
all shifts.
(b)  Systematic workplace walkthroughs shall be conducted by the
health care providers
monthly, and additionally whenever new jobs are established or
existing job tasks change.
The walkthrough shall be conducted to remain knowledgeable about
operations and work
practices, to identify potential light duty jobs, to participate in
identification of risk factors
for CTDs, and to evaluate employee's individual work conditions
through direct
observation.  A record of the walkthroughs shall be kept and shall
document the date,
area(s) visited, risk factors recognized, and action initiated to
correct
identified problems.
(c)  A written ergonomic job analysis describing the various
ergonomic hazards found on
each job shall be developed by an ergonomist and made available to
the health care
providers.  The employees in the health department shall provide
input to the development
of the job analysis.  Periodic review and revision of the ergonomic
job analysis shall be
conducted, particularly when jobs change.  Analysis of the physical
procedures used in the
performance of each job, including lifting requirements, postures,
hand grips, and frequency
of repetitive motion, shall be conducted by an ergonomist or other
qualified person.  The
ergonomist and health care providers shall develop a list of jobs
with the lowest ergonomic
hazard(s).  This light duty job list shall be utilized when
recommending assignments of
restricted or light duty.  Likewise, a list of known high risk jobs
shall be compiled.  Both
lists shall be periodically reviewed and updated by health care
providers
and supervisors.
(d)  A CTD surveillance shall be performed in order to identify jobs
needing intervention
to eliminate ergonomic hazards.  Surveillance shall be both passive,
by reviewing data such
as illness records, and active, through annual administration of an
employee symptom
survey.  The symptom survey shall be conducted to measure employee
awareness of
workrelated
disorders and to report the location, frequency, and duration
of discomfort.  Health
care providers will provide input in this surveillance to identify
high risk departments,
production lines, or jobs.
(e)  A baseline health surveillance shall be conducted for all new
and transferred workers
who are to be assigned to positions involving exposure of a
particular body part to
ergonomic
stress.  The surveillance shall include a medical and
occupational history, and
physical examination of the musculoskeletal and nervous systems as
they
relate to CTDs.
The examination shall include inspection, palpation, range of motion
(active, passive, and
resisted), and other pertinent maneuvers of the upper extremities and
back.  Examples of
the pertinent maneuvers for the hands and wrists include Tinel's
test, Phalen's test, and
Finkelstein's test.
Employees shall be given the opportunity to condition their
muscle-tendon groups during
a 4 to 6 week break-in period with follow-up assessment by health
care providers after the
break-in period.    This assessment is conducted to determine if
conditioning of the
muscletendon
groups has been successful.
Periodic health surveillance every 2 to 3 years shall be conducted on
all workers who are
assigned to positions involving exposure of a particular body part to
ergonomic stress.  The
data gathered as a result of these health surveillance shall be
documented and filed in
individual employee medical records.
(f)  Health care providers and supervisors shall encourage employees
to report early signs
and symptoms of CTDs to the in-plant health facility.  Potential
disincentives to reporting,
such as pay disincintives, discrimination, and/or undesirable
restricted duty shift, shall be
avoided.
(g)  Evaluation and treatment of employees with complaints consistent
with CTDs shall be
based on protocols triggered by medical history and physical
examination.  Written
protocols for health surveillance for the evaluation, treatment and
follow-up of workers with
signs and symptoms of CTDs shall be developed and used.  At least
annually, these
protocols
shall be documented in writing, reviewed, and updated by a
physician.
Based on the severity of the physical signs and symptoms, the health
care
provider shall
decide whether to initiate conservative treatment and/or to refer the
employee promptly to
a physician for further evaluation.  Employees with moderate/severe
symptoms or positive
physical findings shall be immediately referred to a physician for
further evaluation and
placed on restricted duty in the interim period until being evaluated
by the physician.  If
mild symptoms and no physical signs are present, conservative
treatment is recommended.
If initial treatment of the CTD has not resulted in prompt
improvement or resolution of the
signs or symptoms, the employee shall be taken off the job causing
the problem, or placed
on restrictions by the health care provider.  The restricted employee
shall be placed on
appropriate jobs, consistent with their capability and which do not
pose parallel stressors,
by health care providers familiar with the job requirements.
Appropriate assignments to
restricted duty jobs shall be made and tracking of employees shall be
performed so as to
assure that an employee's medical condition is not aggravated or
exacerbated.  Symptomatic
employees shall receive follow-ups with the health care providers to
determine the
effectiveness
of the prescribed treatment.  In no event shall employees with
mild symptoms undergo
conservative treatment for longer that two weeks without first being
referred to a physician
for evaluation.
Conservative therapy, and time away from the job causing the problem,
deserves an
adequate trial before surgical intervention is contemplated.
Recommendations for surgery
shall be referred for a second opinion from a qualified physician.
Appropriate amount of
time off work after surgery shall be assured.  A physical evaluation
of the worker after
time away from work, to assess work capabilities, shall be performed
to ensure appropriate
job placement upon return to work.  The employer shall monitor job
placement to verify
that employees are not exposed to the same or similar stressors which
originally
caused or
contributed to their CTD illness.
If the employee is being medically followed for CTDs, the medical
department will review
the ergonomic analysis on the job causing the problems.  If a job has
no ergonomic analysis
available, the job will be analyzed for ergonomic stressors.
(h)  The health care providers shall be responsible for entering the
appropriate information
onto the OSHA recordkeeping forms and thus shall be appropriately and
adequately trained
on OSHA's recordkeeping requirements.  Health care providers shall
ensure the appropriate
documentation of medical treatment (including self-administered
treatment) and the retention
of such documents.
(i)  Evaluation of the medical management program shall be performed
on a periodic basis
to assure effectiveness of all of the elements.  Periodic (e.g.
quarterly) review of health
care facility sign-in logs, OSHA-200 forms, and individual employee
medical records shall
be conducted by health care providers to monitor trends for CTDs in
the plant, to monitor
employees being treated for CTDs, and to help determine the
effectiveness of the various
programs initiated to decrease CTDs in the plant.
(j)  The foregoing recommendations for specific medical management
actions are made
as a result of the above cited deficiencies as well as the following
problems in the current
medical program observed during the inspection:
(1) The employer failed to ensure that new hires and reassigned
employees were
allowed to gradually resume full duties.
(2) The employer failed to ensure that employees who had
reported CTD signs and
symptoms and/or had entered into a rehabilitation program
due to a CTD
illness(es) were not discriminated against.
(3) The employer failed to ensure that barriers to early
reporting by employees of
CTD signs and symptoms and interference by management with
medical treatment
did not exist since:
(a)  Employees were delayed and/or denied access to in-house
health care
providers;
(b)  Employees were required to complete a mandatory two
week in-house
conservative
treatment period prior to being referred to a
physician regardless of
the type and severity of CTD signs and symptoms
presented, and the
employees believed the conservative treatment to be
ineffective;
(c)  Employees were verbally discriminated against by
management personnel
when under treatment for a CTD illness(es);
(d)  Employees were required to lose pay when placed on the
night light duty
restricted shift as the maximum allowable hours worked
per week was
thirtysix
and overtime was not available; and,
(e)  Employees were placed on the undesirable night light
duty restricted shift
which required working at undesirable times of 8:00
p.m. - 4:30 a.m.
Tuesday  through Thursday, 7:00 p.m. - 12 ;00 a.m. on
Friday, and 10:00
a.m. - 5:30 p.m. on Saturday, and performing
undesirable and sometimes
unsafe tasks in such undesirable areas as Rendering or
the Box Coolers.
(4) The employer failed to ensure that in-house conservative
treatment for CTDs
was appropriate and effective; inappropriate treatment
included the use of splints
on the job while use of the appendage was required, and
ineffective treatment
included the use of vitamin B-6 and hot wax.
(5) The employer failed to ensure that a second opinion was
obtained by a qualified
physician prior to surgical intervention.
(6) The employer failed to ensure that employees returning to
work following time
away were allowed to gradually resume full duties.
(7) The employer failed to ensure that employees were not
returned to regular duty
prior to CTD sign and symptom resolution.
(8) The employer failed to ensure that a plant-wide CTD symptom
survey was
administered on an annual basis; the symptom survey shall be
anonymous.
(9) The employer failed to ensure that all light/restricted duty
jobs were analyzed by
an ergonomist or other qualified person, and that a lit of
light/restricted duty jobs
with the lowest ergonomic risk was developed by an
ergonomist and the health
care provided.
IV.  TRAINING AND EDUCATION of employees, management and health care
providers.
(a)  The physicians providing medical services to the company's
employees need to be
trained in the recognition, evaluation, and treatment of CTDs.  All
first level health care
providers shall be trained in the prevention, early recognition,
evaluation, treatment and
rehabilitation of CTDs, and in the principles of ergonomics, physical
assessment of
employees, and OSHA recordkeeping requirements.
(b)  Health care providers shall participate in the training and
education of all employees,
including supervisors and other plant management personnel, on the
different types of CTDs
and means of prevention, causes, early symptoms and treatment of
CTDs.  New employees
shall be given this training during orientation and shall be repeated
at least annually for all
employees to ensure comprehension and absorption of the subject
matter.  This information
shall be reinforced during workplace walkthroughs and the individual
health surveillance

Issued

Dec 16, 1993

Abate by

Jan 18, 1994

Penalty

Initial $8,000 · Current $4,000 Reduced

Issued

Dec 16, 1993

Abate by

Jan 18, 1994

Penalty

Initial $4,000 · Current $1,000 Reduced